Latest Articles

  • Number of Expatriations Continue to Rise

    By:
    Alicea Castellanos, CPA, TEP, N.P. and Jack R. Brister, TEP
    |
    Sep 1, 2016
    American expats continue to renounce their citizenship at an increasing rate, although the overall percentage taking this step remains relatively small. Driving this trend is the fact that the United States is the sole country in the Organisation for Economic Co-operation and Development (OECD) that imposes taxes on its citizens regardless of where they reside. 
  • Does My Organization Have Unrelated Business Taxable Income?

    By:
    Robert Lyons, CPA, MST
    |
    Aug 1, 2016

    Unrelated business taxable income (UBTI) is a relatively simple concept: It represents activities conducted by an organization that are both (1) commercial and (2) not in furtherance of the organization’s exempt purpose. UBTI is based on the idea that when a nonprofit participates in commercial activities or exploits its exempt purpose, it would be competing at an unfair advantage with for-profit entities because, as a nonprofit, it generally does not pay taxes on its income. 

  • U.S. Announces Greater Scrutiny of Foreign-Owned LLCs: Is Peer Pressure a Motivator?

    By:
    Alicea Castellanos, CPA, TEP, N.P. and Jack R. Brister, TEP
    |
    Aug 1, 2016

    The United States and other jurisdictions have spent a decade trying to identify owners of foreign corporations. Now, a five-year-old report by the Organization for Economic Cooperation and Development (OECD) might have served as an impetus for a U.S. proposal regarding disclosure requirements for limited liability companies (LLCs). 

  • Form 926: Return by a U.S. Transferor of Property to a Foreign Corporation

    By:
    Mitchell Sorkin, CPA, MBA, PFS
    |
    Aug 1, 2016

    This article is the first in a series of articles explaining various IRS forms that relate to the reporting of foreign transactions.

  • Is It Debt or Equity? A Survey of the Proposed Section 385 Regulations

    By:
    James J. Wienclaw, CPA
    |
    Jul 1, 2016
    The fundamental question investors address when capitalizing a business is how it should be funded—with debt, equity, or a combination of both. Considerations can vary widely depending on the level of risk an investor is willing to take or the desired tax treatment.
  • New Seller Due Diligence Responsibilities After the Midco Cases?

    By:
    Ellen S. Brody, CPA, JD, Esq. and Vivek A. Chandrasekhar, JD, Esq.
    |
    Jul 1, 2016
    In the post-General Utilities world, shareholders have looked to dispose of their interest in C Corporations with appreciated assets in a way that would avoid the double taxation arising on a sale of assets followed by a liquidating distribution to the noncorporate shareholder. 
  • U.S. Real Estate Beckons to Foreign Investors in Wake of FIRPTA Revisions

    By:
    Alicea Castellanos, CPA, TEP, NP and Jack R. Brister, TEP
    |
    Jul 1, 2016

    Changes to U.S. tax rules that were signed into law in December have important implications for foreign entities seeking to invest in the U.S. real estate market. This includes both additional disclosure requirements and provisions that may increase the tax efficiency of certain assets.

  • A Few Words About Estate Planning and Trustee Engagements

    By:
    Ron Klein, JD, CFE
    |
    Jul 1, 2016

    Thirty years of protecting CPAs from malpractice risks has shown that every CPA is safer if they understand the risks they are facing. In no type of engagement is this truer than in estate planning and trustee engagements. And the reason for this is clear: hindsight!


  • Mortgage Interest Tax Deduction

    By:
    Daniel Lahage, CPA
    |
    Jun 1, 2016
    During every election cycle, a set of tax proposals set forth by candidates become topics for debate. Whether or not each candidate will actually be able to implement that tax policy is another question. 
  • Tax Haven, USA

    By:
    Erica Rubin, CPA, CGMA
    |
    Jun 1, 2016

    International tax structuring and cross border planning has always been a complex and evolving process. The massive leak at Mossack Fonseca, the Panamanian law firm responsible for setting up countless offshore companies, along with the U.S. Treasury Department’s challenge to the corporate inversion “loophole” have brought forth issues that will again challenge the status of tax havens in the global marketplace.

Tax Quote
 

“The problem is not that the people are taxed too little. The problem is that government spends too much.” 

– Ronald Reagan

*Outside the Box is a new addition to the TaxStringer featuring important articles on financial and investment management topics by top authors who have expertise both inside and outside the realm of taxation.

 

 

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